EARLIER ENFORCEMENT ACTON BROUGHT AGAINST CENTAUR FOR PERMIT VIOLATIONS. PERMIT WAS ISSUED BY U.S. EPA UNDER 42 U.S.C. 300F FOR THE CONSTRUCTION AND OPERATION OF WATER INJECTION WELLS FOR OIL RECOVERY. CENTAUR RECENTLY CEASED INJECTION IN ORDER TO STOP THE ACCUMULATION OF PENALTIES, AND APPLIED FOR AN EMERGENCY PERMIT UNDER 40 C.F.R. 144.34. AT ISSUE IS WHETHER IT MEETS THE 3 CRITERIA FOR ISSUANCE OF AN EMERGENCY PERMIT. I REVIEWED THE PROPOSED LETTER OF WATER DIVISION, WHICH WOULD DENY THE PERMIT, AND PROVIDED MY COMMENTS TO THEM ON MARCH 28, 1988.